Privacy policy

Last updated: August 9, 2019

1.- Responsible Party and Description

1.1.- Responsible Party

The party responsible for processing this site is SUTREIA TRAVEL, S.L. (hereinafter The Company), Calle Goloso 5, 28023 Madrid.

NIF: B16907875

Email: info@sutreia.com

1.2.- Description

The acceptance of the privacy policy of The Company (hereinafter “Privacy Policy”) is a necessary condition for the use of our website, service for purchasing products and/or services, online store, and social networks (hereinafter the “Service”).

This Privacy Policy regulates the collection, processing, and use of your personal and non-personal information as a user of www.sutreia.com, from the effective date appearing in the header.

To process your personal data, The Company complies with current local and European legislation, as well as its development regulations.

2.- Information Collected

The Service can be used without the need to provide any data, although to purchase a ticket, you will need to provide some personal data. The information (personal or non-personal) collected by the Service may vary depending on that.

The personal and non-personal information collected by the Service will reach us through three ways: 1) the information collected automatically, 2) the information you provide voluntarily, and 3) the information provided by third parties.

2.1.- Information Collected Automatically

This information will consist of:

Information collected through cookies or similar mechanisms stored on your device, always with your consent or in accordance with other legal bases. See our Cookie Policy for more information.
The IP address from which the connection is made, the type of device used and its characteristics, the version of the operating system, the type of browser, the language, the date, the country, the time of the request, the URL from which you come, the URL to which you go, or the mobile network used, among others.
Usage data of the Service and possible errors detected during its use.
Additionally, The Company uses Google Analytics, an analytical service provided by Google, Inc. based in the United States, headquartered at 1600 Amphitheatre Parkway, Mountain View, California 94043. For the provision of these services, they use cookies that collect the information, including the user's IP address, which will be transmitted, processed, and stored by Google under the terms set on www.google.com. Including the possible transmission of such information to third parties for reasons of legal requirement or when such third parties process the information on behalf of Google.

In any case, you can disable Google Analytics cookies from here.

2.2.- Information You Provide Voluntarily

This information will consist of:

The information required by The Company to complete the purchase of a product or service: name, surname, email, address, NIF, and phone number.

All data are mandatory.

If you make a reservation on behalf of another person through the Service, for example, as a gift, you guarantee that you have legitimately obtained the personal information of those other people before providing us with their data.

The personal or non-personal information that may be contained in the messages sent through the contact or opinion channels established in the Service, for example, your name, alias, or email.
Your photo, name, nickname, or geolocation if you decide to participate in any of our activities on social networks.
The information required to subscribe to our newsletter, such as your email.

2.3.- Information Provided by Third Parties

This information will consist of:

Information provided by payment systems or credit card processors, such as the time of purchase or its amount.
Information provided by messaging services that deliver your order, such as the date and place of delivery.

3.- Rights and Purposes

We inform you that the completion of the forms is voluntary. However, if you do not fill in the mandatory fields (usually marked with an asterisk), the use of some functions of the Service will not be possible or will be limited.

The personal data you provide will be incorporated and processed in the Record of Processing Activities owned by The Company, among others, to attend to your requests, provide the requested service, and keep you informed about matters related to the company's activity and its services.

You can exercise at any time the rights of access, rectification, deletion, limitation of processing, opposition, and portability of your personal data by email to: info@sutreia.com or by postal address: Calle Goloso 5, 28023 Madrid

In both cases, you must identify yourself with your name and surname, along with a copy of your DNI or national ID.

If you have given consent for any specific purpose, you have the right to withdraw consent at any time, without affecting the legality of the processing based on the consent prior to its withdrawal.

Additionally, if you consider that there is a problem with how The Company is handling your data, you can direct your complaints to the data protection authority, being the Spanish Data Protection Agency indicated in the case of Spain.

4.- Age

Regarding the use of the online service, you declare that you are of legal age and have the necessary legal capacity to bind yourself to this agreement and use the site in accordance with its terms and conditions, which you fully understand and acknowledge.

You declare that all the information you provide to access the Service, both before and during its use, is true, complete, and accurate.

5.- Use of Data

The Company will use the collected data to:

Administer, provide, and update the Service (the legal basis being the contract).
Address the questions you raise (the legal basis being our legitimate interest in addressing our users' requests).
Process the payments you make (the legal basis being the contract).
Share data, such as your image, on our social networks (the legal basis being our legitimate interest in promoting and disseminating our products).
Send you our newsletter and promotional offers via email (the legal basis being your consent or our legitimate interest based on the prior contractual relationship, as the case may be).

You can unsubscribe from these from the received email or by contacting us at the email address info@sutreia.com. However, you will not be able to unsubscribe from certain correspondence from us, such as messages regarding the security of your data or the terms and conditions of the Service.

Maintain the security of the Service, investigate illicit activities, enforce our terms and conditions, and assist state law enforcement agencies in their eventual investigations (the legal basis being our legitimate interest in ensuring and maintaining the security of the Service and its users).

The Company does not use automated decisions, although it may generate basic user profiles, the legal basis being our legitimate interest for commercial purposes and providing personalized offers.

Likewise, The Company may use user information in the form of aggregated and anonymous data to show it to third parties. It may also share statistics and demographic information about users and their use of the Service with third parties. However, this will not allow these third parties to identify you personally.

5.1.- In Emails and Contact Forms

The Service website has SSL encryption that allows the user to securely send their personal data through standard contact forms.

The collected personal data will be subject to automated processing and incorporated into the corresponding files of the record of processing activities owned by The Company.

In this regard:

Your IP address will reach us, which will be used to verify the origin of the message to provide you with appropriate recommendations (for example, presenting information in the correct language) and to detect possible irregularities (for example, possible attempts to cyber-attack the Service), as well as data related to your ISP.
Likewise, you may provide us with your data through telephone, email, and other means of communication indicated.

Regarding the communication means used:

Our payment service providers for paying for our services are VISA and Mastercard. At no time will the Service or its staff have access to the bank details (for example, the credit card number) that the user as a customer provides to these third parties.

On the other hand, certain services provided through the web (for example, the possibility of participating in a contest or promotional code draw) may contain particular conditions regarding personal data protection. It will be necessary to accept them before participating in those services.

5.2.- On Social Networks

The Company has profiles on some of the main social networks, being responsible for the processing of the data published on them (for example, photos uploaded by The Company showing people's faces).

The processing that The Company will carry out with the data within each of the aforementioned networks will be, at most, what the social network allows for corporate profiles. Therefore, The Company may inform, when the law does not prohibit it, our followers by any means that the social network allows about its products or offers, as well as provide personalized customer service.

In no case will The Company extract data from social networks unless the user's specific and express consent is obtained for it.

5.3.- In Draws

By participating in promotional actions organized exclusively by The Company, the data you provide will be treated solely by us for the purpose indicated in the statement of the action and its corresponding legal conditions.

6.- Data Retention

The following indicates how long the data processed by the Service is retained:

Disaggregated data will be retained without a deletion period.
Customer data will be retained for the minimum necessary time, which may be up to:
5 years, according to art. 1964 of the Civil Code (personal actions without a special term).
6 years, according to art. 30 of the Commercial Code (accounting books or invoices, for example).
Newsletter subscriber data will be retained from the time the user subscribes until they unsubscribe.
Data of users uploaded by The Company to its social networks will be retained from the time the user provides their consent, or the data has been uploaded according to The Company's legitimate interest until it is withdrawn.

7.- Data Shared with Third Parties

There are third parties that manage part of the Service.

The Company requires them to comply with this Privacy Policy as applicable to them, in addition to having their own policy. However, The Company will not be responsible for compliance with such policy.

Under certain circumstances, The Company may share, use, or preserve some of the personal information collected with third parties:

To provide the Service:

Service providers who perform functions on our behalf, such as payment services, web hosting, business analytics, customer service, marketing, or merchandising purchase service. These service providers may collect and access the information necessary to perform their functions, but they are not allowed to share or use the information for any other purpose.

To cooperate with the competent authorities:

a) If we believe it is reasonably necessary to satisfy any law, legal process, or legitimate interest anywhere in the world. In any case, we will only provide the information strictly required.
b) If we believe that this action is appropriate to enforce the terms and conditions of The Company.
c) If it is necessary to detect or prevent fraud or issues related to the security of The Company, its suppliers, and users.

8.- Security Measures

The Company adopts all the necessary technical and organizational measures to protect the security and integrity of the personal and non-personal information collected. Both against unauthorized access and accidental alteration, loss, or destruction.

In any case, The Company cannot guarantee the absolute security of the information collected, so you must collaborate and always use common sense about the information shared.

You understand and acknowledge that even after deletion, personal and non-personal information may remain visible in cache or if other users have copied or stored it.

9.- Changes to the Privacy Policy

We may update this Privacy Policy in the future.

We will inform you about its changes by sending a notice to the email address provided and/or placing a notice in a prominent place on our website.

10.- Contact

If you have any questions about this Privacy Policy, contact us at:

Email: info@sutreia.com

Address: Calle Goloso 5, 28023 Madrid